Proposed Rule G-42 would establish core standards of conduct for municipal advisors, provide guidance on the obligations and prohibitions that accompany their federal fiduciary duty to state and local governments, and clarify their duties of care and fair dealing to all clients. BDA’s letter focuses on the following issues: Timing of disclosure of conflicts of interest Principal transactions Documentation…
Category: Comment Letters
BDA Submits Comment Letter on Proposed Rule G-42
BDA’s letter focuses on the following issues: Timing of disclosure of conflicts of interest Principal transactions Documentation of recommendations Reference to Rule G-23 Reference to bank loans The letter is available here. The BDA has also submitted two previous comments letters to the MSRB on this topic, available below. View BDA’s August 25, 2014 comment…
BDA Submits Comment Letter to IRS on Issue Price to Inform 2015-16 IRS Priority Guidance
BDA submitted a comment letter to IRS in response to its request for comment on the 2015-2016 IRS Priority Guidance Plan. The purpose of BDA’s letter is to reaffirm BDA’s concerns with IRS’s proposed rule changes related to issue price if IRS choses to move forward on the proposed rule changes in 2015-16. The letter reaffirms BDA’s previously…
BDA Submits Comment Letter to MSRB Re: Approval to Enhance Post-Trade Data Available on EMMA
Amendments to the MSRB’s Real-Time Transaction Reporting System (RTRS) would require dealers to indicate trades executed on an alternative trading system and trades involving non-transaction based compensation arrangements, among other changes. You can find our final letter here. The BDA’s letter includes discussion on the following: Support for increased transparency Concern regarding additional associated reporting costs…
BDA Submits Comment Letter: FINRA Proposal to Expand TRACE Dissemination to Additional Securitized Products
Today, BDA submitted a comment letter to FINRA in response to its request for comment on a proposal to expand dissemination of TRACE data to include an additional group of securitized products. The BDA’s letter can be accessed here. Proposal Executive Summary: FINRA is soliciting comment on a proposal to expand dissemination of TRACE data to include “additional Securitized…
BDA Letter to Editor Published in Wall Street Journal: Highlights the Impact of Federal Regulatory Burden on U.S. Securities Firms
The purpose of BDA’s letter is to highlight – as Mr. Blankfein fully recognizes – the outsized impact of the current regulatory environment on all U.S. based securities firms, but especially those smaller firms less able to weather dramatic increases in compliance costs. BDA argues, the aggregate impact of the current regulatory environment harms the ability of smaller…
BDA Submits Comment Letters: FINRA and MSRB Proposed Pricing Reference Disclosure Rules
BDA submitted an identical comment letter to both FINRA and MSRB in response to their request for comment on a proposed rule to require a pricing reference disclosure on certain retail-size fixed income trades. The BDA’s letter can be accessed here. The BDA’s letter focuses on several core issues with the proposed rule. Regulators have yet to explore…
BDA Submits Comment Letter: SEC Rule 15c2-12
BDA submitted a comment letter to the SEC regarding its request for comment on SEC Rule 15c2-12. The BDA’s letter is accessible here. The Commission solicited comments on the regulatory burden for underwriters and issuers associated with Rule 15c2-12 compliance. In addition, SEC requests comments on “ways to enhance the quality, utility, and clarity” of information collected…
2014 Year in Review – BDA Federal Advocacy
Regulations & Securities Law FINRA Margin Amendments In January, FINRA published a request for comment on proposed amendments to Rule 4210—margin rules for the TBA market. The proposed amendments would require the collection of margin for exposures greater than $250,000 on a variety of transactions on which there is currently no margin requirement. In March,…
The Bond Buyer Publishes BDA Op-Ed: Clearing Up the Confusion on Non-Dealer MA Registration
This week The Bond Buyer features an op-ed by the BDA entitled, “Clearing Up the Confusion on Non-Dealer MA Registration.” The commentary is in response to an article in The Bond Buyer on December 16 on a letter from the National Association of Municipal Advisors to the SEC requesting “exemptions from broker-dealer and investment adviser…